A judge yesterday seemed to find legal merit in Allegheny County's attempt to use this year's assessment values well into the future, although his final decision may not come for several months.

Common Pleas Judge R. Stanton Wettick Jr. called the county's actions a "back door" approach to establishing values for the county's 550,000 properties. But he acknowledged its compliance with state law.

County officials have made the year of the last reassessment, 2002, a base, following a practice commonly used by many counties across Pennsylvania.

Two sets of homeowners have sued Allegheny County and are calling on county Chief Executive Dan Onorato to release the results of a new reassessment that was completed this year. Mr. Onorato has discarded those numbers.

Donald Driscoll, a lawyer representing a pair of homeowners in Braddock and the Hill District, said a base year doesn't reflect the broad changes in the real estate market since 2002, forcing owners with declining property values -- including his clients -- to pay an unfair share of the tax burden.

"You correctly point out the problem," Judge Wettick told Mr. Driscoll. "People living in a neighborhood that goes up significantly in value are not paying their share. But that's the legislation."

The state Legislature approved the use of base years in 1982, allowing counties to choose not to do regular reassessments.

But Mr. Driscoll said Allegheny County is still required to make regular revisions to address wide discrepancies in assessment values.

Judge Wettick said he didn't think any revisions were required.

"As long as you do base year, you don't look into the future," he said.

Still, the judge allowed Mr. Driscoll another chance to develop his argument, giving him and the county 20 days to submit new briefs. No hearing date was set.

That means many property owners likely will start receiving their tax bills before Judge Wettick makes a final ruling on the lawsuits.

Mr. Driscoll promised a constitutional challenge against the base year if the judge rules in the county's favor.

Yesterday's hearing appeared to be a boost for the county. Mr. Onorato hasn't fared well before Judge Wettick this year. In May, the judge threw out Mr Onorato's plan to put a 4 percent cap on rising assessment values.

The county already has been using a base year, Solicitor Michael Wojcik told Judge Wettick yesterday. Officials have been calculating the values of newly constructed homes by running them through computer formulas used to create the 2002 reassessment.

Mr. Driscoll and Ira Weiss, a lawyer representing homeowners from Franklin Park, Mt. Lebanon and Squirrel Hill, both argued that the county's approach will hurt many homeowners who purchased properties after 2002 and saw their assessments increase because of appeals by school districts and municipalities.

Jerry Speer, the appeals board's acting chairman, said the board has been following state law but will hold discussions about adopting the base year.

Mr. Speer encouraged any property owners with questions about the validity of their assessments to file appeals. The deadline is Jan. 3.

Tom Connolly, executive director of the State Tax Equalization Board, said he didn't agree with Mr. Driscoll's legal argument that the county needs to revise base year values.

"You can't go in and do revisions unless you reassess the entire county," he said.

Mr. Weiss predicted the case would drag on.

"The presents will be unwrapped and the trees will be down when this is over," he said.